Keithan v. Lakeside Environmental Consultants, LLC

CourtDistrict Court, D. Connecticut
DecidedDecember 3, 2024
Docket3:23-cv-00782
StatusUnknown

This text of Keithan v. Lakeside Environmental Consultants, LLC (Keithan v. Lakeside Environmental Consultants, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Keithan v. Lakeside Environmental Consultants, LLC, (D. Conn. 2024).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

STEPHANIE KEITHAN,

Plaintiff, No. 3:23-cv-00782 (OAW) v.

LAKESIDE ENVIRONMENTAL CONSULTANTS, LLC.

Defendant.

ORDER GRANTING MOTION TO COMPEL Defendant Lakeside Environmental Consultants, LLC ( “ECI“) moves pursuant to Fed. R. Civ. P. 37 and Rule 37 of the Local Rules of Civil Procedure for the United States District Court, District of Connecticut (“Local Rules”) to compel Plaintiff to respond to certain interrogatories and requests for production. See ECF No. 24. Plaintiff Stephanie Keithan filed suit against Defendant alleging that ECI violated the Americans with Disabilities Act (“ADA”) and Connecticut Fair Employment Practices Act (“CFEPA”) by terminating her employment during an “extended leave of absence” to treat a cancerous mass. Plaintiff alleges ECI’s termination of her employment constitutes disability discrimination, a failure to accommodate her disability, and retaliation under the ADA and CFEPA. See ECF No. 1. For the foregoing reasons, the court GRANTS in part and DENIES in part Defendant’s motion to compel. BACKGROUND Plaintiff filed her Complaint on June 15, 2023. ECF No. 1. On August 10, 2023, Defendant responded with its Answer. ECF No. 14. Shortly thereafter, this court prompted the parties to file their Rule 26(f) report, which had been due on or before August 24, 2023. ECF No. 15. The parties belatedly submitted their Rule 26(f) report,

and the court issued a scheduling order. ECF No. 17. Discovery was to have been completed by October 22, 2024. ECF Nos. 30, 33. Thus, the parties were provided over one year to conduct discovery in this employment discrimination case. On February 13, 2024, Defendant served its discovery requests on Plaintiff’s counsel. ECF No. 24-1, pg. 3.1 Plaintiff served her first set of discovery requests on April 18, 2024. ECF No. 24, pg. 5. Given the experience and expertise of the parties, it is unclear why five months passed before the first set of discovery requests were served in this case. Nevertheless, Plaintiffs neither timely responded to Defendant’s discovery requests nor sought an extension of such deadline. However, for its part, Defendant did not raise this

issue until April 22, 2024 – four days after Plaintiff submitted her discovery requests to ECI’s counsel. See ECF No. 24-2, pg. 35. On May 23, 2024, ECI deposed the plaintiff who averred, among other things, that nobody instructed her to preserve documents related to her allegations in this matter. Id. at 43 (Tr. 17:5-18:6).2

1 Page numbers cited in the instant ruling refer to those assigned by the court’s electronic filing system and not necessarily to counsel’s pagination. 2 Counsel’s obligation to inform clients of their responsibility to preserve case-related documents is well established. Chan v. Triple 8 Palace, Inc., No. 03-cv-6048 (GEL) (JCF), 2005 WL 1925579 at *6 (S.D.N.Y. Aug. 11, 2005) (“The preservation obligation runs first to counsel, who has ‘a duty to advise his client of the type of information potentially relevant to the lawsuit and of the necessity of preventing its destruction.’”). Failing to do so is a factor to be weighed by a court in imposing sanctions. Chin v. Port Auth. of New York & New Jersey, 685 F.3d 135, 162 (2d Cir. 2012). On May 29, 2024, Plaintiff submitted responses to Defendant’s discovery requests. According to Defendant, it “noted significant deficiencies with Plaintiff’s responses, including missing information that Plaintiff had specifically promised to produce during her deposition.” Id. at 4. Defendant does not say when it noticed the deficiencies, and indeed did not raise this concern for over one month, until, on July 8, 2024, ECI’s counsel

“emailed Plaintiff’s counsel regarding the deficiencies in Plaintiff’s responses to Defendant’s discovery requests and asking that Plaintiff provide supplemental responses on or before July 15, 2024.” Id. at 92 (Exh. 6). And while parties lack the court’s authority to compel responses by a certain date, the deadline issued by Defendant was to avoid its filing of a motion to compel, despite its own delays in providing notice of this deficiency. Two days, later, on July 10, 2024, Defendant timely submitted its discovery responses. Whereas Plaintiff alleges they were “21 days after [D]efendant’s extension [had] expired,” ECF No. 27 at 5, through counsel, she previously had granted Defendant an extension through July 10, 2024, see ECF No. 28 at 12 (noting, “July 10 is fine” for such deadline,

given the Independence Day holiday). Accordingly, Defendant’s submission appears to have been timely. See also Fed. R. Civ. P. 29(b). Thereafter, on July 16, Plaintiff appears to have raised concerns with Defendant’s discovery compliance, see ECF no. 28 at 3, and one week later, on July 23, 2024, Defendant followed up on its July 8 email and requested to meet and confer with Plaintiff’s counsel regarding the discovery deficiencies, either that day or the following afternoon. ECF No. 24-2 at 100. Defendant again threatened that failure to comply would result in the filing of a motion to compel. Id. Within four minutes, Plaintiff agreed to meet the following afternoon, clarifying that both parties should raise their lingering concerns. Id. However, Defendant then failed to confirm its own availability (within the timeframe it demanded) for another two days, which was beyond Defendant’s stated meeting window which it deemed necessary to avoid its filing of a motion to compel; indeed, Defendant’s delayed response was despite Plaintiff’s immediate notice of counsel’s availability to meet within the short timeframe initially set by Defendant itself. Id. at 105. Moreover, six days

later, on July 29, Plaintiff reduced to writing several remaining discovery disputes. Id. at 114. Thereafter, and without responding in writing to those discovery claims, Defendant then complained that it had not received a response from Plaintiff in order to schedule a time to meet and confer as to the parties’ discovery concerns and it requested that Plaintiff respond (yet again) “as soon as possible.” Id. Apparently, Defendant’s emergency remained, but its own unilateral interim discovery deadline had been reset due to Defendant’s own unresponsiveness to Plaintiff’s immediate confirmation of availability. On August 13, 2024, the parties held a discovery conference call. ECF No. 27. Plaintiff’s counsel claims that during the call, ECI’s counsel “would only talk about their

own discovery deficiencies.” Id. at 7. For its part, defense counsel represents that “it was communicated to Plaintiff’s counsel that undersigned counsel . . . was only available to speak for thirty minutes.” ECF No. 28, pg. 3. However, Defendant does not dispute that it refused to use any of that time to discuss Plaintiff’s concerns. Instead, Defendant filed the instant motion to compel the day after that call, which the court notes to have come nearly one year after the start of discovery, see ECF Nos. 16–17, and approximately two weeks before close of discovery as such deadline had then been set, see ECF No. 22. Thereafter, the court granted an extension of the discovery deadline to October 18, 2024. See ECF Nos. 29, 30. Defendant’s motion seeks to compel Plaintiff to produce more detailed responses to its interrogatories and requests for production.

DISCUSSION Defense counsel does not entirely appear to have approached the August 13, 2024,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Chin v. Port Authority of New York & New Jersey
685 F.3d 135 (Second Circuit, 2012)
United States v. All Assets Held at Bank Julius Baer & Co.
309 F.R.D. 1 (District of Columbia, 2015)
Design Strategy, Inc. v. Davis
469 F.3d 284 (Second Circuit, 2006)
Robinson v. United States
205 F.R.D. 104 (W.D. New York, 2001)
Trilegiant Corp. v. Sitel Corp.
272 F.R.D. 360 (S.D. New York, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
Keithan v. Lakeside Environmental Consultants, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keithan-v-lakeside-environmental-consultants-llc-ctd-2024.